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The issues for decision are: (1) Whether petitioner is
collaterally estopped from denying that he received bribe income
during the years in issue. We hold that he is not. (2) Whether
petitioner received unreported bribe income during the years in
issue. We hold that he did. (3) Whether petitioner is liable for
additions to tax for fraud pursuant to section 6653(b).1 We hold
that he is. (4) Whether respondent is precluded from assessing
tax for the years in issue due to the running of the statute of
limitations. Due to our holding in issue 3 above, we hold that
she is not.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
herein by this reference. At the time the petition herein was
filed, petitioner resided in Pompano Beach, Florida.
Petitioner
Petitioner received a Bachelor of Science degree in
accounting from the Drexel Institute of Technology in 1949. From
1953 to January of 1981, petitioner was employed as a Revenue
Agent with the Examination Division of the Philadelphia Office of
the Internal Revenue Service (IRS). As a revenue agent,
petitioner was responsible for conducting examinations of filed
1 All section references are to the Internal Revenue Code in
effect for the taxable years in issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure, unless
otherwise indicated.
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